Privacy

Privacy Statement

This external Privacy Policy (the “Policy”) gives you information about the way we collect and use data identifying you or that makes you identifiable (“personal data”), in the course of all your interactions with us (except to the extent we are interacting with you in your capacity as (former, current or prospective) employee or as self-employed hired by us).

We, Saper Vedere, a company with limited liability set up under the laws of Belgium, with registered office located at Rue Maurice Wilmotte, 17, 1060 Bruxelles, and registered at the Crossroads Bank for Enterprises under the company number 679771446 (“Saper Vedere”) are committed to protecting your privacy. We will aim to comply with applicable data protection legislation, including the EU General Data Protection Regulation 2016/679 and the Belgian data privacy act of 8 December 1992 (FR/NL), as may be amended, restated and/or replaced from time to time.

What personal data we may collect on you?

We may process the following personal data on you:

Name

Surname

Organisation

Function

Twitter handle

Professional telephone number

Professional address

Professional email

In some cases, depending on the project and the agreed task to perform, we may also process your:

Personal email

Langages spoken

When visiting our website, we may process some electronic identification data (e.g. IP & MAC addresses, the pages you accessed on our website, the links you clicked, the sites visited prior to visiting our website, country and city).

We also use cookies on our website (Google analytics cookies). [Please refer to the section about cookies to obtain information about our use of cookies.]

If you post any materials (e.g. pictures, videos, etc.) or any other information (e.g. comments) on a feed or a page of our website or on a feed or a page of our social media accounts, we may use any personal data contained in (or relating to) such materials or information.

For which purposes do we process your personal data?

We may process your personal data for the following purposes:

To communicate with you and to maintain and improve customer relationships;

To process any payments related to your commercial transactions with us;

To deliver services, products and/or promotional materials to you;

To send you seasonal/festive greetings or messages;

For security reasons;

To respond to our client issues;

To engage with you on our website and social media accounts;

To respond to your queries;

To prepare requests for proposals;

To improve our online presence or provide IT ;

Why do we use your personal data?

We process your personal data because it is necessary for the performance of our contractual relationship (e.g. process payments, customer relationship, etc.) or to take steps at your request prior to entering into a contract.

We process some of your personal data to comply with legal obligations applicable to us (e.g. pursuant to accounting or tax laws).

We process some of your personal data when this is in our legitimate interest (e.g. security, improvement of our online presence, etc.).

How long do we keep your personal data for?

Saper Vedere has internal retention policies and procedures that build upon the following criteria to determine the retention periods of personal data in the context of the purposes set out above:

Time elapsed since your last interaction with our website;

End of the contractual relationship with a supplier or a third party provider of products or services;

Sensitivity of the personal data;

Security reasons;

Applicable statutes of limitation;

Ongoing or potential litigation or dispute;

Regulatory or legal obligation to retain the personal data (e.g. for accounting purposes).

Whom do we share your personal data with?

We may provide personal data to the following recipients, only to the extent necessary to achieve the purposes set out above:

Our employees or self-employed hired by us;

Subcontractors;

Consultants;

Legal counsel;

Tax agencies.

We never disclose your personal data to third parties in the context of their marketing activities.

International transfers of personal data

If we transfer personal data internationally, we will only do so in accordance with applicable data protection laws and will ensure that there is an adequate level of protection for the personal data.

Personal data may be transferred from countries located within the European Economic Area (EEA) to countries located outside of the EEA. If personal data is transferred outside of the EEA, the following safeguards are taken:

The laws of the country to which personal data is transferred to ensure an adequate level of data protection; or

The transfer is subject to data protection clauses approved by the European Commission or is subject to the EU-US Privacy Shield.

For more information about the safeguards relating to personal data transfers outside of the EEA, please contact us at ‘access@saper-vedere.eu”

Your rights

Depending on and subject to applicable laws, you have certain rights regarding the personal data that we hold on you. These rights may include the following:

The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Policy.

The right of access

You have the right to obtain access to your personal data.

This is so you are aware and can check that we are using your personal data in accordance with applicable data protection laws.

The right to rectification

You are entitled to have your personal data rectified if it is inaccurate or incomplete.

The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not an absolute right to erasure and exceptions apply.

The right to restrict processing

You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further.

The right to data portability

You have rights to obtain a copy of your personal data in a commonly used machine-readable format and to reuse your personal data for your own purposes across different services.

The right to object to processing

You have the right to object to certain types of processing, including processing for direct marketing (which we perform only with your consent).

The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection authority. For Belgium, the competent data protection authority may be contacted at Rue de la Presse/Drukpersstraat 35, 1000 Brussels.

The right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

The right not to be subject to automated-decision making

You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal (or similarly significant) effects to you.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

Baseless or excessive/repeated requests; or

Further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we practically can, generally within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.

Contacting us

If you need to contact us for any reason (including to exercise any of your rights in relation to your personal data as set out above) please send us your request at access@saper-vedere.eu